BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Internal Controls Checklist 7.1: Currency Transaction Reporting

Policies, Procedures, and Processes

Yes No

N/A

Determine whether the financial institution's policies, procedures, and processes adequately address the preparation, filing, and retention of Currency Transaction Reports (CTRs). For paper reports filed before July 1, 2012, review correspondence that the financial institution has received from the IRS Detroit Computing Center relating to incorrect or incomplete CTRs (errors). Determine whether management has taken corrective action, when necessary. Review the currency transaction system (e.g., how the financial institution identifies transactions applicable for the filing of a CTR). Determine whether the financial institution aggregates all or some currency transactions within the financial institution. Determine whether the financial institution aggregates transactions by taxpayer identification number (TIN), individual taxpayer identification number (ITIN), employer identification number (EIN), or customer information file (CIF) number. Also, evaluate how CTRs are filed on customers with missing TINs or EINs. The financial institution's independent testing confirms the integrity and accuracy of the management information systems (MIS) used for aggregating currency transactions. The auditor should confirm the integrity and accuracy of the MIS. Has the auditor confirmed that tellers do not have the capability to override cash aggregation systems?

Y

NA

y

Y

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